TRI Toolkit Q&A

A facility must report the ultimate disposition of listed toxic chemicals from the facility during the reporting year. Listed toxic chemicals remaining in the sediments after the sludge is sent off-site to a recycler are 'released to land.' Listed toxic chemicals sent to a receiving stream when the wastewater is drained are 'released to water.'

Listed EPCRA section 313 chemicals remaining in the pond after the sludge has been removed should be reported as “released to land.” Listed EPCRA section 313 chemicals left in the pond water, which have been drained off, should be reported according to their disposition: either discharged to a stream (back into the cooling pond), discharged to a POTW, transferred to other off-site locations, treated on-site, or recycled on-site.

In this situation, Facility A and Facility C would report the toxic chemicals transferred to Facility B, as an off-site transfer in Part II, Section 6.2 using treatment code M90, other off-site management and in Section 8.1 as released. Facility B would not consider these toxic chemicals towards their otherwise use threshold because Facility B does not receive toxic chemicals in waste from off-site for disposal on-site under EPCRA section 313. If, however, Facility B meets an activity threshold for these chemicals elsewhere at the facility, it would report the release of the chemicals in the wastewater received from Facility A and the stormwater from Facility C in Part II, Section 5.3 and 8.1 of the Form R.

Yes, the facility must report the release of the listed acid if it meets the threshold criteria for reporting. The facility was acting as operator of the waste treatment site and must report listed chemicals otherwise used in excess of the threshold. Because the facility operates the lagoon and it is adjacent to the rest of the site, the lagoon is part of the facility (40 CFR Section 372.3).

If chlorine is present in waste released by a facility it must be reported even though the chlorine may be transformed in the environment subsequent to the release. If the chlorine is transformed in the waste stream prior to any releases, the facility must still report if an activity threshold is met, but the amount reported may be zero.

Estimating emissions based on the amount used overestimates releases since chlorine is only slightly soluble in water, it reacts with chemicals in the water and it dissipates in side reactions. Multiplying measured residual chlorine by recirculation rate by lost water fraction may also overestimate releases (residual includes other forms of chlorine), but may be the only way to make a reasonable estimate. Please refer to EPA’s EPCRA section 313 Reporting Guidance for Food Processors (EPA 745-R-98-011; August 1998).

Yes. The facility must consider their use of a reportable acid as an on-site release to land even though subsequent to the release the acid may be neutralized in the process of cleaning the well. EPA does not allow facilities to reduce the quantity reported as released to the environment based on conversions of a chemical in the environment after the chemical has been released by the facility.

No, fugitive releases are emissions that are not in a confined directional air flow. Since your building vent system over the painting room is a confined air stream, it can be combined with the oven stack as a stack or point emissions in Part II Section 5.2 of the Form R.

Reporting leaks from pipes requires determining where the released toxic chemical goes. For example, a toxic chemical that evaporates would be reported as a fugitive air emissions in Part II, Section 5.1 of the Form R. A nonvolatile material leaking into land, or any material leaking from an underground pipe, would be reported as a release to land and entered in Part II, Section 5.5.4 'Other Disposal.' In either case, the toxic chemical would also be reported in Section 8.1.

Release calculations based solely on the efficiency of the unit may not be sufficient. Facilities must use the best readily available information. For example, the 99.99 percent efficiency of an incinerator may not refer to the destruction and removal of the chemical being reported on the Form R. If that is the case, the efficiency may have no relation to the release quantity of the chemical being reported. Even if the surrogate waste is the chemical being reported, the 99.99 percent efficiency may not only include the quantity of the chemical destroyed by combustion, but may also include the quantity of the chemical that is physically removed. The quantity of the chemical removed can include undestroyed chemical in the ash, and undestroyed chemical discharged from air pollution control devices like scrubbers, precipitators, baghouses, etc. Furthermore, releases of the chemical due to faulty equipment upstream from the feeding point of the combustion device can also be counted as quantity removed and included in the 99.99 percent efficiency calculation. As a result, release calculations based solely on the efficiency of the unit might count the chemical removed as destroyed. This will result in under-reporting of the quantity of the chemical released to the environment.The facility should also examine its operating records to account for chemical releases during upset conditions such as those released from an emergency dump stack.

Metals cannot be destroyed by combustion. Therefore, the efficiency of a combustion unit has no relation to the releases of metals from the unit.

EPA interprets 'friable' under EPCRA section 313 '...as being crumbled, pulverized, or reducible to a powder with hand pressure' (53 FR 4519; February 16, 1988). Facilities are required to report releases or other waste management of only the friable form of asbestos. The facility will report zero releases of friable asbestos to land because the ethylene glycol/asbestos mixture is not considered to contain friable asbestos since the asbestos contained therein is wet (i.e., with ethylene glycol). The facility would report the amount of friable asbestos that is treated in Part II, Section 8.6. Note that because ethylene glycol is also a listed toxic chemical, the facility would also need to consider this chemical for threshold determinations and release and other waste management calculations.

EPA does recognize that a toxic chemical can lose its chemical identity in a reaction by being converted into a new chemical. The facility must still account for the amount they either manufacture or process regardless of whether the listed toxic chemical is converted to another toxic chemical in the process. Releases and other waste management estimates must then be calculated for any part of the process involving the Section 313 listed toxic chemical. In addition, if the byproduct created is a listed toxic chemical, the facility must consider it toward the manufacturing threshold.

Potential monitoring data sources can include stack monitoring data, outfall monitoring data, air permits, industrial hygiene monitoring data, National Pollution Discharge Elimination System (NPDES) permits, publicly owned treatment works (POTW) pretreatment standards, effluent limitations, Resource Conservation and Recovery Act (RCRA) permit data, hazardous waste analysis, pH for acids, and continuous emissions monitoring. The basis of estimate code used in Section 5 or 6 of the TRI Form R for monitoring data is either M1 or M2, depending on whether the estimate was based on continuous monitoring data (M1) or periodic or random data or measurements (M2).Potential data sources for mass balance calculations can include supply records, a hazardous material inventory, an air emissions inventory, pollution prevention reports, hazardous waste manifests, and spill event records. The applicable basis of estimate code for mass balance calculations is C.Potential emissions factors can include AP-42 emissions factors, other EPA emissions factors, published facility or trade association chemical-specific emissions factors, site-specific emissions factors relating release quantity to through-put or equipment type (e.g., air emissions factors), or other site-specific emissions factors developed specifically for a situation or process on-site that takes into account the actual field conditions at the location. The applicable basis of estimate code is either E1 or E2, depending on whether the estimate was based on published emissions factors (E1) or site-specific emissions factors (E2).Other potential data sources can include engineering calculations, best engineering judgment, volatilization rates, Raoult's Law, Henry's Law, and solubilities. The applicable basis of estimate code for these types of other approaches is O.The potential sources and factors provided above are only examples. A facility can use any source of information so long as the source is consistent with EPCRA section 313(g)(2): the owner or operator of a facility may use readily available data (including monitoring data) collected pursuant to other provisions of law, or, where such data are not readily available, reasonable estimates of the amounts involved. For more details on release estimate calculations, refer to the TRI Reporting Forms and Instructions (Appendix B).

The company should use the code M if it measured releases of the toxic chemical from its equipment at the facility to determine its release amount. 'E' is used only for published emissions factors which are chemical specific. However, in this case, the company would use 'O' which is used if it measured leaks generally or applied non-published factors developed at other facilities.

Report the basis of estimate code associated with the technique used to calculate the major portion of each release entry. See examples in the current Form R instructions.

Yes, SOCMI fugitive emissions factors can be used for the petroleum refining industry even though they are based upon synthetic organic chemicals manufacturing. The refinery user would have to correct for differences in concentrations of the mixtures, because SOCMI factors are based upon pure substances being released.

Published emissions factors by sources other than EPA that contain chemical specific emissions rates may be reported as 'E'. Published emissions factors that are not chemical specific are indicated as 'O'.

Use 'O' for non-chemical-specific emissions factors.

The E1 code indicates that the estimate is based on published emissions factors, such as those relating release quantity to through-put or equipment type (e.g., air emissions factors). These emissions factors are generated from data published by trade associations and other organizations and take into account averages for a type of activity for specific process/equipment/sector(s) to achieve a general emissions factor. AP-42 emissions factors would fit most likely under E1. The E2 code indicates that the estimate is based on site-specific emissions factors, such as those relating release quantity to through-put or equipment type (e.g., air emissions factors). These emissions factors are developed specifically for a situation or process on-site and take into account the actual field conditions at the location, rather than an average across the industry. Additional information about emissions factors is available in AP-42, Compilation of Air Pollutant Emissions Factors. AP-42 is available at the following URL: https://www.epa.gov/air-emissions-factors-and-quantification/ap-42-compilation-air-emissions-factors.

The air emissions reported in Section 8.1 should be 52 pounds unless the facility has better information about their emissions. Facilities are not allowed to use range codes in Section 8 of the Form R. In this instance, the owner or operator seems to have estimated their fugitive emissions from data relevant to the listed toxic chemical and the activities occurring at their facility.

In using emissions factors to determine fugitive emissions to the air from leaks in pipes, a facility must use the total amount of time over which a pipe contains the listed toxic chemical, since a release will occur whether a toxic chemical is moving or stagnant in the pipe.

There is no definite way to determine if a chemical in storm water is associated with that year's production or is from legacy wastes. A facility should use its best available information, based on available monitoring data and knowledge of conditions at the facility, to estimate the amount of a listed EPCRA section 313 chemical in storm water resulting from that year's production. In the absence of documentation, listed EPCRA section 313 chemicals found in storm water should be reported as current releases.

The composition should be counted once the rainwater has run onto and off equipment, concrete pads, etc. as a portion of the total facility release to surface water.

The facility would put 'city-owned storm sewer' or the equivalent because this is all they know. To leave the stream or water body name item blank or put 'NA' would be identified as an error when the Form R is entered into the computerized database of Section 313 data.

The facility should not report NA for the releases to the land, if the facility spills a toxic chemical on the ground. If the facility spills ten pounds of a relatively volatile chemical such as dichloromethane (CAS number 75-09-2) with a high vapor pressure (435 mm Hg) and low adsorption coefficient (Koc = 28), virtually all ten pounds would be expected to volatilize to air. In this case, the ten pounds would be reported in Section 5.1 and zero pounds under section 5.5. NA should only be used in this section to indicate that there have been no releases to land. Although one may expect all of the volatile chemical to volatilize, the zero in Section 5.5 indicates that there was an opportunity for the toxic chemical to remain on the land.

While either notation, NA or zero, may be entered in Part II, Section 8.8 of the Form R, they are not synonymous. If a remedial action, catastrophic event, or one-time event not associated with production processes results in a release into the environment or an off-site transfer of the listed chemical that is not a chemical of special concern and the annual aggregate release was less than 0.5 pound, then a facility owner/operator should enter zero in Section 8.8. For chemicals of special concern, facilities should report releases and other waste management amounts greater than 0.1 pound (and for dioxin and dioxin-like compounds 0.0001 gram) at a level of precision supported by the accuracy of the underlying data and the estimation techniques on which the estimate is based. (see (64 FR 58734; October 29, 1999) and Guidance for Reporting Toxic Chemicals with the Dioxin and Dioxin-like Compounds Category (EPA-745-B-00-021)). An owner/operator should only report NA for Section 8.8 on the Form R if no release or transfer occurred as a result of these activities.

If you report NA, leave the basis of estimate box blank or enter NA. If you report zero releases then you need to provide a basis of estimate.

No. A facility must enter 'NA' to inform the Agency that the submitter has not just overlooked a section of the Form R.

No. It is only appropriate to report 'NA' when there is no possibility that a release could have occurred to a specific media or off-site location. In Part II, Section 5.5.4, the facility is required to report any amount of a listed toxic chemical released to land that does not fit the categories of landfills, land treatment, or surface impoundments. This includes any spills or leaks of the listed toxic chemical to land. While there were no known spills or leaks to land of benzene, the possibility did exist that a release could have occurred. In this situation, the facility should report 0 in Section 5.5.4 and provide a basis of estimate (see the Toxic Chemical Release Inventory Reporting Forms and Instructions).

You must estimate emissions of the total mixture using average molecular weight and vapor pressure for the mixture, then multiply by the mole fraction of the toxic chemical in the gaseous emission. The required formulas are found in the referenced technical guidance document but are not listed in a step-by-step procedure.

The partial vapor pressure of toluene in formulations, which is a function of its vapor fraction and mole fraction (not weight percent), can be used. See Appendix C, of Estimating Releases and Waste Treatment Efficiencies (1999 version).

Covered facilities should calculate emissions of the mixture then adjust for concentration. Convert chemical fractions from weight to mole, calculate the mixture's true vapor pressure, calculate the chemical's vapor mole fraction, calculate the average vapor molecular weight, and use storage tank equations to calculate mixture emissions. Then calculate the gaseous weight fraction and multiply by total mixture emissions to get each chemical's emissions. Facilities may choose to refer to EPA’s technical guidance entitled Estimating Releases and Waste Treatment Efficiencies (1999 version)

Fugitive emissions from drums in storage at a covered facility may include emissions from opening and emptying the drums. The facility may consider each drum as a small tank and estimate the amount of toxic chemical contained in the vapor space using methods such as partial pressure determinations found in EPA’s technical guidance document, Estimating Releases and Waste Treatment Efficiencies (1999 version) for the Form R.

If available, data on the average composition for the specific material or published data on similar substances should be used.

The owner or operator of the manufacturing facility should report the toxic chemical as sent off-site for recycling in Section 6.2 (Transfers to Other Off-Site Locations) and in Section 8.5 (Quantity Recycled Off-Site). The manufacturing facility owner or operator is only responsible for reporting toxic chemical releases and other waste management activities from his/her own facility. If the TSD that recycles the manufacturer's waste is subject to EPCRA section 313 reporting, the TSD owner or operator would report releases resulting from the recycling activity.

The federal facility is required to use the best data available at the facility to identify the final, known disposition of an EPCRA section 313 chemical that it is reporting on a Form R report for the purpose of entering a waste management code in Part II, section 6.2.C of the Form R. While obtaining additional information from the off-site location concerning the fate of the particular EPCRA section 313 chemical is not required, it is certainly an option for facilities who lack a complete understanding of the final disposition of an EPCRA section 313 chemical in a waste sent off-site.

EPCRA requires facilities to submit the most accurate readily available information. If facilities do not have information on the removal and destruction rates for a chemical transferred to a particular POTW, then they may use the chemical-specific default POTW rates provided in TRI-MEweb. TRI-MEweb has assumed the chemicals ultimate disposition using experimental and estimated data on removal and destruction rates at POTWs compiled by EPAs Risk-Screen Environmental Indicators (RSEI). The percentages that EPA provides are automatically pre-loaded in TRI-MEweb and are applied to quantities provided in Section 6.1 to assist with Section 8 calculations and as guidance for users who do not know the ultimate disposition of their off-site transfers to POTWs. If the facility has more accurate information readily available on the final disposition of the subject chemical, users should edit the default values and use the more accurate information in place of the default percentages.

Parts per million (ppm) of a toxic chemical in wastewater indicates the concentration of a toxic chemical, not the actual total mass of the toxic chemical.Only the actual mass of the toxic chemical being released should be reported. A million pounds of wastewater stream containing 1 ppm of the toxic chemical is equivalent to one pound of the toxic chemical.

For fixed roof tanks, the working loss equation for vertical tanks can be used. For breathing losses, one can still use the vertical tank equation, except that an effective tank diameter must be substituted for D in the equation. D is the square root of {(4)(area of liquid surface)}/?. H is the same as for vertical tanks.

Yes, this Section of the Form R applies only to the treatment of waste streams containing toxic chemicals that occur on-site at the reporting facility.

If a facility has several pieces of equipment performing an identical service in a waste treatment sequence, you may combine the reporting for such equipment. It is not necessary to enter four codes to cover four scrubber units, for example, if all four are treating waste streams of similar character (e.g., sulfuric acid mist emissions), have similar influent concentrations, and have similar removal efficiencies. If, however, any of these parameters differ from one unit to the next, each scrubber should be listed separately.

No, the use of the absorbent would not be considered treatment for Section 8 of the Form R but it would be treatment of the waste stream in Section 7A of the Form R. Only if the toxic chemical was destroyed, such that it was no longer the chemical subject to EPCRA section 313, would that activity be considered treatment in Section 8. If the absorbent were drummed and sent to a landfill, that would be listed as a transfer to an off-site location for disposal. Any amount of the toxic chemical left on the ground must be accounted for as a release to land and reported in Part II, Sections 8.1 and 5.5.

Covered facilities that use Section 313 chemicals for pH adjustments and neutralization must report if they meet the otherwise use threshold, even if these chemicals are consumed and no releases result. The listed toxic chemical is reported as zero pounds discharged to the POTW in Section 6.1 (Discharges to Publicly Owned Treatment Works) and the entire amount neutralized is reported in Section 8.6 (Treated On-Site). The neutralization process is reported under Section 7A of the Form R (On-Site Waste Treatment Methods and Efficiency).

Since there is a potential for discharge of the particular toxic chemical to the POTW, the discharges to the POTW on Part II, Section 6.1 of the Form R would be reported as zero rather than NA.

If the stream is a named, recognizable waterway, then the facility should report the discharge as a release to water in Part II, Section 5.3 and report the name of the receiving stream in the same Section. If the release is not to a named, recognizable waterway, the release should be reported as a release to land.

Facility owner/operators must report the name of each stream to which toxic chemicals being reported are directly discharged. You should report the name of the receiving stream or water body as it appears on the NPDES permit for the facility. If the stream is not named in a permit, enter the name of the off-site stream or water body by which it is publicly known or enter the first publicly named water body to which the receiving waters are a tributary, if the receiving waters are unnamed. You should not list a series of streams through which the toxic chemical flows, but only the first water body it enters from your facility. Do not enter names of streams to which off-site treatment plants discharge. Enter 'NA' in Section 5.3.1, if you do not discharge the listed toxic chemical to surface water bodies.

Since Grove Creek is the first named receiving stream, it should be listed in Part II, Section 5.3.1 even though the waste is not directly discharged into it.

If the facility does not have specific measures for land filling, land farming, or land disposal, then for the purposes of the Form R, the releases would be entered on Part II, Section 5.5 4 (Other Disposal). This would apply to amounts released that were not cleaned up and removed from the site or otherwise treated and disposed on-site.

The material does not have to be reported as released, if the concrete containment area is part of regular processing operations (or is designed to catch such materials in the event of an accidental spill, etc.). However, any material that is not further used (e.g., there are fugitive air emissions or transfers off-site) must be reported in the appropriate sections on the Form R.

For purposes of reporting under EPCRA section 313, EPA considers a reportable acid waste stream that has been neutralized to a pH above 6 to be completely neutralized. However, if the pH is below this level (e.g., 5.5), calculate the amount of acid released based on the amount of base it would take to raise the pH of the waste stream to 7 (not 6). For more information on pH measurements, EPA has published Estimating Releases and Waste Treatment Efficiencies for Mineral Acid Discharges Using pH Measurements (EPA 745/F-97-003).

Because the nitric acid is neutralized to a pH 6 or above during on-site treatment, no nitric acid is present in the filter cake sent off-site for disposal. Therefore, the off-site transfer would not be reported in the Form R for nitric acid. The on-site waste treatment of the nitric acid must be reported in Part II, Section 7A (On-Site Waste Treatment Methods and Efficiency) and in Section 8.6 (Quantity Treated On-Site). In addition, the facility must determine if the neutralization of the nitric acid in the filter cake results in the manufacture of a water dissociable nitrate compound category in an aqueous solution, which is a listed category under EPCRA section 313.

The quantity of toxic chemical washed down the drain would need to be reported as a transfer to a POTW in Section 6.1, regardless of the existence of a discharge permit (see 40 CFR Section 372.85(b)(15)).

The facility should not have reported all of the benzene which was placed in the on-site lagoon as a release to land. The majority of the benzene will evaporate. The purpose of sending a waste to a lagoon is so that the volatiles (in this case benzene) will evaporate and the solids will settle. The facility should have determined, to the best of its ability, what percentage of the benzene would evaporate during that reporting year. It should have reported this amount as a fugitive air emission. The balance should have been reported as a release to land. Both the amount reported as a fugitive air emissions and the amount reported as a release to land should have been reported for 1995, the year when the wastes containing the benzene were placed in the on-site lagoon. When completing the Form R for benzene for reporting year 1996, the facility would not report as a release to land any benzene in sludge that was transferred from the on-site lagoon to the on-site landfill as this material was already reported as a release to land on the Form R for the previous year. However, the facility must report on the Form R for benzene for reporting year 1996 any air emissions of benzene that occurred as a result of transferring the sludge from the on-site lagoon to the on-site landfill if the facility met the threshold for benzene.

If Company B is a 50-50 joint venture between Companies A&C, it is not owned, operated or controlled by Company A and therefore is a separate facility from Company A. Since Company B knows the ultimate disposition of the toxic chemical, Company B should report the off-site location as Company A in Part II, Sections 6.2 but should report the type of waste management activity that will ultimately be performed in Part II, Sections 6.2 and 8 on the Form R. If Company B had not known the ultimate disposition of the waste, it would report the toxic chemicals in waste as an off-site transfer for storage only, using waste management code M10 in Part II, Section 6.2 and report the toxic chemical as released in Section 8.1 of the Form R.

Yes. Covered facilities must consider amounts manufactured, processed, or otherwise used toward threshold determinations each year. Provided these amounts are not associated with exempt activities and reporting thresholds have been exceeded, amounts released, including disposed, are reportable during the year in which the releases occur. If an amount of a listed toxic chemical previously disposed of is manufactured, processed, or otherwise used in a subsequent year then the facility should consider these amounts as it would new materials brought on-site, and report any waste management activities that are associated with toxic chemicals for which thresholds have been exceeded.

Storage tanks and railcars or tank trucks are similar operations. However, it is the nature of releases rather than their source that is most important in their classification for reporting. Because emissions from railcars and tank trucks are most often small, scattered, and the result of manual transfer operations, they are considered fugitive. Emissions from storage tanks, meanwhile, are most often considered point source because they are usually from vents, ducts, or other confined air streams. If a covered facility has sufficient reason to believe that the nature of releases from rail cars and tank trucks are similar to those of storage tanks, they may report them as point source emissions, or vice versa. The facility must, however, document all assumptions and estimates made to support their reasoning.

Releases from the covered facility (i.e., barge terminal) must be reported. This would include releases from buildings, equipment, and storage at the terminal. The barge terminal ends where the equipment physically meets the barge. Releases from the barge itself (e.g., air displacement of volatiles) are not reportable since barges are not covered under the definition of a facility (see 40 CFR Section 372.3).

The amount of listed toxic chemical collected in the basin would be considered on-site storage. However, any leaching into the ground or volatile air emissions would be reported as releases to land and air, respectively, in Part II, Sections, 5.5.4 (Other Disposal) and 5.1 (Fugitive or Non-Point Air Emissions) of the Form R. Also, if the toxic chemical is sent off-site to the treatment facility during the reporting year, it is reported as an off-site transfer in Section 6.2 of the Form R.

The facility must account for the amount of the listed toxic chemical released to various environmental media. Reporting of releases is based on the entire reporting year. If during the year an amount in dusts that settle out are collected and disposed of, then this would be reported in an amount disposed of on-site or off-site in the appropriate Section of the Form R (e.g., if the dusts are sent off-site for disposal they would be reported in Part II, Section 6.2). Any amount of toxic chemical in dusts that remain airborne would be reported as a fugitive release (Part II, Section 5.1 of the Form R). Amounts released that settle outside of a building on facility structures or equipment that are not collected and disposed of should be reported in Part II, Section 5.5.4 of the Form R as a release to land on-site.

If the facility can develop a reasonable estimate of that part of a release to air that is deposited within the facility (and subsequently collected or deposited in an on-site landfill or surface impoundment), then these quantities can be separated from the air release figure(s) and reported as released to land on-site. The remaining air releases not deposited on the facility would be reported as releases to air.

If the facility has reasonable estimates about what percent of stack particulate emissions lands on-site, this quantity of toxic chemical would be reported in Part II, Section 5.5.4 (Other Disposal) and the remaining amount of toxic chemical (including the amount deposited on an off-site property) would be reported in Part II, Section 5.2 (Stack or Point Source Air Emissions).

The amount of lead-contaminated soil brought on-site, from off-site, mixed with on-site remediation waste, and placed in an on-site landfill, would be reported in Part II, Section 5.5.1 and Section 8.1, but NOT Section 8.8. This is not remediation material, because it was not generated on-site, but merely brought on-site for treatment. The on-site remediation waste would be reported in Section 8.8. In addition, beginning with reporting year 1998, the covered facility would also consider this quantity towards its otherwise use threshold.

If the threshold for lead has been exceeded elsewhere at the facility, the amount of lead in the contaminated soil would be included in the release reporting. If the ultimate disposal is removing the soil to a hazardous waste landfill off-site, then this would be reported in Part II, Section 6.2 of the Form R as a transfer to an off-site location for disposal, rather than an on-site release to land. In addition, beginning with reporting year 1991, releases and other off-site waste management associated with remedial actions are also reportable in Part II, Section 8.8 of the Form R.

No. All releases and other waste management of an EPCRA section 313 chemical resulting from remedial actions should be reported under Part II, section 8.8 (as well as in sections 5 and 6) of the Form R and are not to be reported under Part II, sections 8.1 through 8.7 of the Form R.

If a federal facility exceeds reporting thresholds for the chemical in other non-exempt activities at the facility then the release of that EPCRA section 313 chemical from one medium to another due to remediation activities must be reported on the Form R, unlike EPCRA section 313 chemicals that transfer to another medium as a result of natural migration. Releases of EPCRA section 313 chemicals that occur as a result of remediation activities during the reporting year are reported in section 8.8 and the appropriate sections of Part II, sections 5 and 6 of the Form R report.

Amounts of listed toxic chemicals placed on land are considered released under EPCRA section 313. However, for reporting purposes, material that is placed on-site during a reporting year does not have to be reported as a release to land on-site if the pile was only used for temporary storage during the reporting year. EPA will consider the pile used for temporary storage if: (1) the facility routinely made off-site transfers of material from the pile during that reporting year; or (2) the facility had a contract in place to transfer the material before the end of the reporting year and transferred the material containing listed toxic chemicals off-site before that year's report was submitted or by July 1, whichever comes first. However, quantities of the toxic chemical that volatilize or leach into the ground as a result of the on-site temporary storage must be counted as released on the Form R.

Material that is added to a pile during a reporting year does not have to be reported, for that reporting year, as a reportable release to land on-site if the pile is used only for temporary storage. EPA will consider the pile used for temporary storage if the facility routinely made off-site transfers of material from the pile during that reporting year. The facility must transfer the toxic chemical off-site before that year's report is submitted or by July 1, whichever comes first.If a facility did not make such routine transfers during a reporting year in which material was added to the pile, EPA will consider the pile used for disposal and the quantity of listed toxic chemical placed on the pile during that reporting year and present at the end of that year must be reported, as a release to land, regardless of the facility's intention to transfer the material off-site in an ensuing year. If, in an ensuing year, such material is transferred off-site, the movement would be reported as a transfer off-site (assuming a threshold for the chemical transferred has been exceeded during that reporting year).

Yes. Spent munitions containing EPCRA section 313 chemicals that are placed on-site, with no immediate intent to transfer the waste off-site, must be reported as a release to land if the facility meets a reporting threshold for that chemical elsewhere at the facility. An immediate intent to transfer the wastes off-site may be demonstrated if: (1) spent munitions containing the EPCRA section 313 chemicals have been routinely sent off-site during the reporting year; or (2) the facility has a contract in place to transfer spent munitions containing the EPCRA section 313 chemicals off-site before the end of the reporting year, and actually transfers the spent munitions before the year’s report was submitted or by July 1, whichever comes first.

Waste stored on a concrete pad must be counted as a release to land if the facility intends to leave the material on the pad for an indefinite period. If the facility routinely uses the pad for 'temporary' storage of waste until enough waste is accumulated and then sends the waste off-site for treatment or disposal purposes, or otherwise management activities on-site, then the 'temporary' storage need not be reported as a release to land within the reporting year when it is 'temporarily stored' and only those amounts released from the pad, such as runoff, would be reported as released, provided thresholds have been exceeded elsewhere at the facility.

Waste rock containing toxic chemicals that is added to stockpiles during a reporting year does not have to be reported for that reporting year, as a reportable release to land on-site, if the stockpile was only used for temporary storage. EPA will consider the pile used for temporary storage if the facility routinely made off-site transfers or processed on-site waste rock from the stockpile during the reporting year, has good documentation of the transfers or amounts processed, or has contracts in place to transfer the materials prior to that year's reporting deadline, and removes or processes all of the listed toxic chemicals from the stockpile before that year's report is submitted or by July 1, whichever comes first. Listed toxic chemicals placed in piles during the previous year that remain after the July 1 reporting deadline must be considered toward the facility's release and other waste management calculations, provided that thresholds for those chemicals have been exceeded.

Yes. The facility is required to report the copper in the waste rock tailings as a release to land in both the current reporting year and in the subsequent reporting year. The facility must report the releases and other waste management activities that occur in each reporting year for material that undergoes a non-exempt activity (i.e., facility is not required to consider any further releases of materials that have been disposed of and are not subjected to further management activities).

Yes. Toxic chemicals that have been released in one reporting year, must also be reported in subsequent years when the material undergoes non-exempt activities, provided certain thresholds have been exceeded. The facility is required to report the listed toxic chemical in the waste rock as a release to land because the toxic chemicals have been displaced and subsequently 'released' or disposed in a following reporting year.

Provided that the facility exceeded a threshold for the toxic chemicals, the facility should report a release of 6,000 pounds of the toxic chemical as landfilled on-site in Part II, Section 5.5.1B (Disposal to Land On-site) and as release in Section 8.1 (Quantity Released). Eight thousand pounds of the toxic chemical (i.e., 5,000 pounds deposited in January and the 3,000 pounds deposited in a prior reporting year) were processed and should be counted towards the processing threshold for the facility for the reporting year. EPA recognizes that by placing the toxic chemical into the landfill, the facility has released the toxic chemical. Nevertheless, EPA will allow facilities to consider quantities that are temporarily stored in a landfill and removed during the same reporting year to not be reported as release in Part II, Sections 5 and 8.

The listed toxic chemical in the slag that is sent off-site for further use as cement material is not reported as an off-site transfer in Part II, Section 6.2 of the Form R. However, the facility must consider the quantities of toxic chemical repackaged and shipped off-site for reuse toward the facility's processing threshold.

Covered facilities are required to report information on off-site transfers for purposes of recycling in both Sections 6 and 8 of the Form R. In Section 6, the facility should report the final disposition of which it has knowledge of the toxic chemical in the waste. When a facility knows that a toxic chemical in wastes sent to a broker is ultimately being recycled, but does not know the location of the recycler, the waste broker is considered the final destination, and the transfer should be reported as M93 (transfer to waste broker-recycling) along with the location of the waste broker. If the location of the recycler to whom the broker sends wastes containing the toxic chemical is known, the recycler is considered the final destination, and the transfer should be reported as recycling with the appropriate code. The location of the recycler, not the waste broker, should be reported. The facility would also report the amount of the listed toxic chemical sent off-site for recycling in Section 8.5 (Quantity Recycled Off-Site).

When reporting off-site transfers of waste in Part II, Section 6.2 of the Form R, it is acceptable to enter M93 in Section 6.2.C only if you do not know the final disposition of the listed toxic chemical. A reporting facility must also identify whether the listed toxic chemical was sent off-site for treatment, energy recovery or recycling in Part II, Section 8 of the Form R.

Covered facilities must report all underground injection of toxic chemicals regardless of permit status.

The amount of the toxic chemical manufactured would be considered toward the facility's chemical activity threshold. However, in this situation, the listed toxic chemical does not undergo any recovery steps, it merely changes physical state and is directly reused. Processes that directly reuse a listed toxic chemical on-site are not reported on the Form R as recycled in Part II, Section 8.6.

The reporting facility is not required to list sequential waste treatment steps for waste sent off-site. The facility should report in Part II, Section 6.2 the one code that best describes the primary type of waste management activity occurring within the sequence and report the total quantity of the listed toxic chemical sent to this off-site location.

Facility A must report the amount of toxic chemical in waste sent off-site for disposal as an off-site transfer for disposal. The facility should report this amount in Part II, Section 6.2, using disposal code M73, and in Section 8.1. The facility should not report the amount released to air during off-site application to land, since this activity did not occur on-site. In Part II, Section 5.1, facilities should only report amounts of toxic chemicals that are released on-site.

If the toxic chemical in the byproduct is sent off-site to be directly reused as a fertilizer, then the transfer would not be considered a transfer off-site for waste management purposes, and Facility A would not report, as a transfer off-site for waste management, the amount sold/given away. However, because the facility distributed the toxic chemical into commerce, the facility must consider the quantity of toxic chemical shipped off-site for direct reuse (i.e., both the amounts given away and sold) as fertilizer as processed for threshold determinations.

Though the drums are recycled, the final disposition of the toxic chemical is unknown. Because this facility does not know how the toxic chemical is managed, the toxic chemical should be reported as an unknown disposal, code M99 (Unknown Disposal) in Part II, Section 6.2.C and quantity released in Section 8.1.

If the facility knows the car will be refilled, the residue is not counted as an off-site transfer. If the facility knows it will be cleaned out and the quantity disposed or otherwise managed as waste, it must be counted as an off-site transfer for disposal.

In order to report the listed toxic chemical as recycled off-site, the reporting facility must have positive knowledge that the listed toxic chemical being reported is actually being recycled by the off-site facility.

The facility should consider the wastewater as a transfer off-site to the POTW since the POTW is ultimately responsible for the release. The POTW has the authority to allow or prevent that release and it enters the stream under their NPDES permit. Because the covered facility knows that the POTW does not treat (destroy) the listed toxic chemical but allows it to pass through into the stream, the facility should also report the quantity sent off-site in Part II, Section 8.1 (Quantity Released).

No. If there are no releases of the toxic chemical to the receiving stream noted in the NPDES permit, the facility would not need to list the stream name. However, the NPDES permit number must be supplied whether or not there are releases of the specific reported chemical to a receiving stream or water body.

The amount of a toxic chemical in the solvent sent to another facility for distillation is reported as a transfer of the toxic chemical to an off-site location for recycling (i.e., it should be reported in Part II, Sections 6.2 and 8.5 of the Form R). The quantity of the solvent returned to you must be treated as if it were a quantity of the toxic chemical purchased from any other supplier and must be used for threshold determination.

The material sent to the launderer is considered an off-site transfer. The facility could use code M90 (Other Off-site Management) or M99 (Unknown Disposal) in Part II, Section 6.2.C of the Form R if it does not know the final disposition of the toxic chemical in the rags.

The facility should give the name of the off-site transfer facility as it was known on December 31 of the reporting year; that information being the most accurate and up-to-date information known.

If an off-site location such as a solid waste landfill does not have a RCRA identification number, the facility would enter 'NA' in the space provided. If the facility does have such a RCRA identification number, it must list the number, if known, even though the waste being transferred may not be a regulated RCRA hazardous waste.

TRI-MEweb has a search feature to standardize entry of off-site location information. Users may first search for the off-site transfer location using the city, county, state, or zip code for the facility. Alternatively, you may manually enter the information of the off-site transfer location.

Section 6.2 of the Form R requires you to report the actual amount of listed toxic chemical you send off-site. The efficiency would be taken into account by the off-site facility if they are reporting under Section 313. The 100,000 pounds of the toxic chemical that are treated on-site should be reported in Part II, Section 7A and in Section 8.

A toxic chemical in a waste stream sent off-site for waste fuel blending is considered combusted for energy recovery if the listed toxic chemical has a significant heat value and is combusted in an energy recovery device. EPA believes that waste blended into fuel will be combusted in an integrated energy recovery device. Where both elements are met, the quantity of the toxic chemical must be reported as an off-site transfer for purposes of energy recovery on the Form R. However, other reportable toxic chemicals in the waste (e.g., metal pigments) that are incombustible or that do not add significant heat value to energy recovery upon combustion must be reported as off-site transfers for purposes of waste treatment or disposal, as appropriate. Please note that metals cannot be treated or combusted for energy recovery purposes and, therefore, should be reported as disposed in Section 8 of the Form R, unless the facility has knowledge the metals are being recycled.

No. While coal tar is a by-product of destructive distillation in the production of coke, it is not a waste. Therefore, EPA would not interpret its combustion to be a waste management activity and it would not be reportable in Section 8 of the Form R

No. The quantity of EPCRA section 313 chemical reported in Part II, sections 7B and 8.2 of the Form R as used for energy recovery include EPCRA section 313 chemicals present in wastes, not in raw materials. Therefore, the combustion of EPCRA section 313 chemicals contained in fuel that occurs in a motor vehicle engine is not considered a reportable energy recovery method on the Form R report.

Even though the treatment plant is located within the boundaries of the petrochemical plant, it is neither owned nor operated by the same person as the petrochemical plant. Therefore, the treatment plant and the petrochemical plant are separate facilities. Since the petrochemical plant does not directly treat the waste, it is not responsible for filling out Part II, Section 7A (Waste Treatment Methods and Efficiencies), on its Form R for the toxic chemical.The petrochemical plant reports only two off-site transfers: (1) the total amount of toxic chemical that is sent to the treatment plant (along with the name and address of the treatment plant); and (2) the amount of listed toxic chemical that is sent to a landfill in sludge (along with the name and address of the landfill). This can be interpreted as reporting a portion of the toxic chemical twice, but since the treatment plant is a separate facility, the total amount sent to the treatment plant has to be reported as an off-site transfer. The petrochemical plant does not need to report the receiving stream since the waste is not discharged directly from the petrochemical plant to the receiving stream.

Report only the combined (or aggregate) waste stream and report the treatment and its efficiency. However, a waste stream that is treated before combination with other wastes, which are then subsequently treated, should be reported on a separate line.

The facility should report influent concentration for the first step and report overall treatment efficiency for the entire process as per the Form R instructions.

For metal compounds, the calculation of the reportable concentration and waste treatment efficiency must be based on the weight of the parent metal, not on the weight of the metal compounds. Metals are not destroyed, only physically removed or chemically converted from one form to another. The waste treatment efficiency reported must represent only the physical removal from the waste stream (except for incineration), not the percent conversion from one form to another. If a listed waste treatment method converts but does not remove a metal (e.g., chrome reduction), the method must be reported with a waste treatment efficiency of zero.